The existence of convertible debt, incentive stock options, warrants, and preferred stock, along with the need for additional capital, creates opportunities for tech companies to issue additional qualified small business stock in 2013.
Advertisement
TOPICS
C Corporation Income Taxation
Earnings and Profits Computation Case Study
It is important for businesses organized and taxed as regular corporations to maintain a current, accurate accounting of their earnings and profits (E&P).
R&D Tax Credits for Food and Beverage Companies
Food manufacturers should look closely at the R&D tax credit even if, in the past, they did not believe their activities in developing new products or processes qualified as technological research.
Sec. 199 Deduction and Contract Manufacturing Arrangements: Who Gets the Deduction?
The IRS issued new guidance to examiners in its Large Business & International Division regarding how to determine which taxpayer is entitled to claim the Sec. 199 domestic production activities deduction in a contract manufacturing arrangement.
Repair Regulations Are Finally Issued
The IRS issued long-awaited final and proposed regulations regarding the treatment of expenditures incurred in acquiring, producing, or improving tangible assets.
IRS Explains Sec. 179 Qualified Real Property Allocations and Procedures for Filing Amended Returns
The explained how the retroactive extension of the Sec. 179 rules operates when applied to qualified real property and how to allocate the portion of gain attributable to the qualified real property upon disposition or to calculate any carryover.
Proposed Regulations Change Definition of R&D Expenditures
In proposed regulations , the IRS provided guidance on the treatment under Sec. 174 of R&D expenditures incurred in connection with the development of tangible property, including pilot models.
Leveraging Existing ERP Systems to Automate Use Tax Compliance
Today’s corporate tax departments are questioning whether they really need expensive bolt-on software for use tax compliance.
ATNOLs and Charitable Contribution Carryovers: Which Takes Precedence?
The uncertainty surrounding the ordering rules of the 10% limit on the charitable deduction and the 90% limit on the ATNOL deduction has been affecting more corporate taxpayers as the economy recovers and these corporations start generating current-period taxable income.
IRS Issues New Final and Temporary Regulations on Outbound Reorganizations
The IRS recently issued temporary and final regulations addressing certain outbound transfers of property, indirect stock transfers, and certain outbound asset reorganizations.
IRS Reverses Itself on Applying 70% Safe-Harbor Deduction for Success-Based Fees to Certain Milestone Payments
The IRS offers an elective safe harbor to deduct 70% of qualified success-based fees, and while certain “milestone payments” common to acquisition transactions do not qualify for the safe-harbor election, certain “eligible milestone payments” do.
Defining Stock of Insolvent and Bankrupt Corporations
This article discusses the special rules and issues surrounding the classification of stock ownership of corporations that are insolvent or in bankruptcy.
Final Sec. 336(e) Regulations: Election for Qualified Stock Dispositions
The IRS issued final regulations under Sec. 336(e) allowing a domestic corporation to make an irrevocable unilateral election to treat the sale, exchange, or distribution of a domestic corporation’s stock meeting the 80% vote and value requirements of Sec. 1504(a)(2) within a 12-month disposition period.
NOL Carrybacks Limited by Excess Distributions
While practitioners typically think of the application of the CERT rules in cases of debt-financed distributions or stock acquisitions, the rules could apply even if the underlying transaction is not debt-financed.
Final Regs. on Acceleration of COD Income Deferral
The IRS issued final regulations on the rules to accelerate COD income that taxpayers elected to defer over a five-year period when an applicable debt instrument was reacquired by the issuer or a related party in 2009 or 2010.
Buying or Selling C Corporation Stock
Unlike an asset sale, a taxable stock sale does not result in the recognition of taxable income or loss at the corporate level, although selling shareholders may recognize taxable gain on the sale of their shares.
Provision of Services by Corporation to Shareholder Not a Constructive Dividend
The Tax Court held that the sole shareholder of a corporation did not receive a constructive dividend when the corporation provided construction services to the shareholder at cost.
Chief Counsel Provides Guidance on Allocating Acquisition-Related Costs
This item summarizes some of the relevant rules that govern the tax years of subsidiaries that join or leave a consolidated group.
2012 Best Article Award
Winners of The Tax Adviser’s 2012 Best Article Award.
IRS Issues Final Rules on Exceptions From REIT or RIC Built-in Gain Recognition
The IRS issued final regulations that provide guidance on the recognition of built-in gain in certain transfers of property from a C corporation to a RIC or REIT.
INDIVIDUALS
Current Developments in Taxation of Individuals: Part 1
This update surveys recent federal tax developments involving individuals, including court cases, rulings, and guidance issued during the six months ending October 2025.
